Golden State Transit Corp. v. City of Los Angeles

Supreme Court of the United States · 1989 · Torts

493 U.S. 103 (1989)

Updated July 19, 2026

tortsSection 1983federal preemptionlabor lawNLRA42 U.S.C. § 1983Machinists preemptionSupremacy Clause

Facts

Los Angeles conditioned renewal of Golden State Transit Corp.'s taxicab franchise on settlement of a labor dispute between Golden State and its union. In Golden State I, the Supreme Court held that the city's action was preempted by federal labor law because it interfered with the collective-bargaining process. After remand, Golden State sought compensatory damages under 42 U.S.C. § 1983 for the city's conduct. The lower courts denied that remedy, concluding that preemption under the NLRA did not create rights enforceable through § 1983.

Issue

Does the National Labor Relations Act create rights in an employer, protected against governmental interference with the collective-bargaining process, that are enforceable in an action for damages under 42 U.S.C. § 1983?

Rule

Section 1983 is available for violation of a federal statute when the plaintiff asserts a federal right, meaning the statute creates obligations sufficiently specific and definite for judicial enforcement, is intended to benefit the plaintiff, and the interest is not too vague and amorphous; even then, the remedy is unavailable if Congress specifically foreclosed § 1983 by express provision or by creating a comprehensive enforcement scheme inconsistent with a § 1983 action. The Supremacy Clause itself does not create rights enforceable under § 1983, but a preemptive federal statute may do so if it creates rights, privileges, or immunities in the plaintiff.

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In Portland, Oregon, Harbor Line Coaches, a private shuttle company, is in contract negotiations with its drivers' union during a lawful strike. The city council tells Harbor Line that its airport-access permit will be renewed only if it agrees to the union's demand for immediate wage increases.

If Harbor Line sues the city under 42 U.S.C. § 1983 for damages, what is the strongest argument that the suit may proceed?

Explanation. A § 1983 claim requires a federal right, not merely a conflict with federal law. The majority held that the NLRA, as interpreted through the Machinists doctrine, gives both employers and employees a right to be free from governmental interference with permissible economic weapons in bargaining. It also held that Congress did not foreclose § 1983 because the labor board lacks authority to remedy governmental interference of this sort.